غرامه ماليه ضخمه من هيئه الرقابه nfa
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تصميم برامج تعمل لصالح الشركه و ليس لصالح العميل
غرامه 2 مليون و تعويضات 3.5 اي بمجموع 5.5 مليون دولار
مصدر الخبر و به قرار nfa مصور و بالدليل
http://forexmagnates.com/nfa-hits-fx...-it-over-3-5m/
NFA hits FXDD with multiple charges including asymmetric slippage, fine will cost it over $3.5m
NFA  just charged FXDD with myriad accounts of alleged violations of its  rules. Details are below. To the best of our knowledge several more  firms are on NFA’s radar and have been heavily audited in the past year.  This is a result of the audit NFA announced back in January 2010 which  then lead to FXCM being hit with a big charge costing it more than $16  million in fines and customer credits. Following all this NFA finalized  its rules on Slippage and Requoting.
Interesting facts:  As of March 1, 2011 (when NFA commenced its 2011 audit of FXDD), FXDD  had approximately 70,000 U.S. clients. 99% of them traded on the MT4  platform.
“NFA’s 2011 audit of FXDD revealed deficiencies  associated with the firm’s recordkeeping, its anti-money laundering  (“AML”) program and other areas of the firm’s operations. In conjunction  with the 2011 audit, NFA also conducted an investigation of FXDD’s  order execution practices, which revealed that the firm treated price  slippage differently (i.e., asymmetrically) when the price slippage  favored FXDD as opposed to when the price slippage favored a customer.”
NFA  goes as far as to claim that “during NFA’s investigation, senior  employees of FXDD, including Green (FXDD’s Chief Compliance Officer –  MG), engaged in a deliberate course of conduct designed to mislead NFA  and others in connection with activity related to the accounts of  certain FXDD customers.”
It seems that this in particular set NFA off.
Main Complaint:
“To  make an IE (Instant Execution – MG) trade, a customer clicks on the bid  or offer price seen on the customer’s computer screen, and FXDD  simultaneously tags the screen price as the price at which the customer  placed his/her trade (i.e., “tagged price”).
For example, in an  IE trade, if a customer wants to buy 100,000 EUR/USO where the bid price  on the customer’s computer screen is 1.43 and the ask price is 1.45,  the customer would click on the ask price of 1.45 to buy the contract  and that would be the tagged price captured on the front-end of FXDD’s  system. However, before executing the trade and confirming it to the  customer, FXDD would also run the customer’s order through two primary  “checks” – a “margin check” and a “price check” – on the back-end of  FXDD’s system. The “margin check” ensures that the customer has adequate  funds to make the trade, while the “price check” ensures that when the  back-office system receives the customer order that the tagged price  remains within certain price parameters based on current market prices.  After these “checks” are completed, FXDD either fills the customer’s  trade at the tagged price of 1.45 or rejects the trade.
During a  visit to FXDD in June 2011, NFA discovered that FXDD had been using  asymmetrical price slippage settings since becoming an NFA Member in  December 2009. These asymmetrical slippage settings were activated  during the “price check” process when FXDD’s system compared the  customer’s tagged price to current market prices. If, after the customer  entered his/her order, the market moved in the customer’s favor  (“positive slippage”) by no more than two pips, then FXDD would fill the  customer at the tagged price. On the other hand, after the customer  entered his/her trade, the market moved in the customer’s favor by more  than two pips, then FXDD would reject the order. However, FXDD did not  follow this same practice if the market moved in FXDD’s favor. In this  situation, FXDD would allow the market to move an unlimited number of  pips in the direction favorable to FXDD, without re-quoting or rejecting  the customer’s order. As a result, FXDD always filled the customer’s  order at the tagged price, even if the tagged price was far outside the  prevailing market price at the time the order was executed. Under such  circumstances, the customer’s position would be unprofitable the very  instant it was executed.
NFA attempted to determine the monetary  harm to customers that resulted from FXDD unequal slippage settings.  Toward this end, NFA requested data from FXDD for executed trades from  December 2009 to June 2011. FXDD produced trading data for the requested  period, which Green assured NFA was complete trade data for executed  trades during the period in question. NFA went to great lengths and  expended an inordinate amount of resources over several months reviewing  and analyzing the data FXDD had provided to NFA and which Green had  assured NFA was complete trade data. However, because of erroneous  statements Green had made about the trade data, which stemmed from his  lack of understanding how FXDD captured its data, NFA was unable to  verify representations Green had made about FXDD’s trading system or to  draw any conclusions concerning the monetary harm to customers that  resulted from FXDD’s unequal slippage settings.
In order to try  and understand the data, NFA returned to FXDD’s offices in April 2012  and spoke with Shawn Dilkes (“Dilkes”), the head of information  technology for the firm. Through conversations with Dilkes as well as a  demonstration of a test account, NFA and Dilkes determined that Green  had previously provided NFA with inaccurate information about the  trading data that the firm had originally provided to NFA. It was little  wonder, therefore, that NFA was confused by such data.
Through  the meeting with Dilkes, NFA was able, at last, to obtain a complete and  accurate understanding of the trading data for the period from December  2009 to June 2011 and was able to complete its analysis, which, among  other things, confirmed that FXDD had used asymmetrical slippage  settings during the above period.
NFA was also able to compute  the monetary impact of FXDD’s asymmetrical slippage practices by  analyzing the number of trades FXDD filled outside the two-pip slippage  tolerance setting – which resulted in orders being filled detriment of  the customer and to the benefit of FXDD, instead of the order being  rejected which is what occurred if the price moved more than two pips in  favor of the customer. The table below summarizes the number of trades  FXDD filled outside the two-pip tolerance setting and the extent to  which FXDD benefited financially from this price slippage practice.”
(This one is going to cost FXDD at least $3.4 million – MG)
Further allegations:
“In  December 2011, NFA received a complaint from a customer that FXDD had  removed profits from the customer’s account. NFA investigated this  customer’s complaint’s and found that since November 30, 2011, FXDD had  removed profits totaling almost $280,000 from nine customer accounts.  According to Green, FXDD unilaterally decided to remove the profits from  these nine customer accounts because the customers had “manipulated”  FXDD’s trading system by executing trades at allegedly “off-market”  prices.
In early February 2012, NFA’s Compliance Department  notified FXDD that, based upon the information the firm had provided  NFA, to date, the firm had violated numerous NFA Forex Requirements.  Specifically, NFA informed FXDD that by unilaterally removing profits  from the nine customers’ accounts – based upon unsubstantiated claims  that certain trades took place at “off-market” prices FXDD appeared to  have converted customer funds and engaged in activities that were  inconsistent with just and equitable principles of trade.”
FXDD  claimed that these clients ‘injected’ prices into FXDD’s platform and  manipulated trades. FXDD was then granted a temporary restraining order  by Manhattan court against these clients which NFA claims was 
achieved  under a false pretense and was a method to buy time
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